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IRS notices • Administrative appeals • Tax disputes
Utah IRS Appeals & Tax Court Disputes
Received an IRS audit determination, Notice of Deficiency, or other letter disputing your return? We help Utah taxpayers evaluate assessment disputes, administrative appeals, filing deadlines, and available litigation options.
Call 801-899-6064Request a Free ConsultationDisagree With the IRS? Identify the Notice First.
The number on an IRS notice helps determine your rights and deadlines. An examination proposal, a 30-day appeals letter, and a statutory Notice of Deficiency are not interchangeable. We review your notice and the underlying records to determine whether you may pursue administrative review, a Tax Court petition, or another procedure.
IRS Letters and Forms People Search For
Notice CP3219A / CP3219N
Statutory Notice of Deficiency in common individual-return and nonfiler contexts. Review the mailing date and the Tax Court petition deadline printed on the notice.
IRS Letter 531 / Letter 3219
Notices of Deficiency in certain examination cases. These may start the statutory petition period; do not confuse them with a 30-day proposal.
IRS Letter 525 / Letter 950
Common examination letters associated with proposed changes and administrative appeals procedures. Follow the precise instructions and response deadline on your letter.
IRS Notice CP2000
A proposed underreporter adjustment, often based on mismatched income records. A CP2000 is not itself a Notice of Deficiency. A timely factual response can matter.
IRS Form 12203
Request for Appeals Review. A form used in qualifying smaller cases to request IRS Independent Office of Appeals consideration.
U.S. Tax Court Petition
Tax Court petitions must comply with the court’s filing requirements. Court representation is limited to practitioners admitted or otherwise authorized to practice before the court.
IRS Administrative Appeals vs. U.S. Tax Court
Administrative Appeals
The IRS Independent Office of Appeals considers disputes through administrative procedures. Depending on the issue, a protest, Form 12203, supporting records, and legal analysis may be required.
Tax Court Proceedings
In qualifying deficiency cases, a timely Tax Court petition can permit review before payment of the disputed tax. We assess the notice, deadlines, jurisdiction, and availability of admitted Tax Court counsel when court representation is needed.
A legal dispute may involve income characterization, disallowed deductions, business expenses, unreported income, penalties, or procedural issues. The right approach depends on the specific notice and record.
U.S. Tax Court official website · IRS Independent Office of Appeals
What to Have Ready for Your Free Consultation
The IRS notice
Keep the entire letter, date of mailing, envelope when available, and all attachments.
Tax records
Relevant returns, schedules, audit correspondence, supporting documents, and prior appeals.
Deadline information
Tell us the specific response or petition deadline shown on the notice, including any imminent dates.
IRS Appeals and Tax Court FAQs
Is CP2000 the same as CP3219A?
No. CP2000 proposes changes; CP3219A is a statutory Notice of Deficiency that generally starts the Tax Court petition period.
Can I appeal IRS audit results?
Often, but the applicable administrative process and deadline depend on the letter and issue.
Does requesting an IRS appeal extend a Tax Court deadline?
Do not assume it does. Read the notice and obtain legal advice promptly.
Can any attorney represent me in U.S. Tax Court?
Not automatically. Tax Court practitioners must be admitted or otherwise authorized to appear. We assess available representation and appropriate counsel for the matter.
Owe an established IRS balance you cannot pay? Explore Offers in Compromise.
Speak With a Utah Tax Attorney
Call Rogers & Russell to discuss your IRS notice, tax debt, and available next steps. Ask about a free initial consultation.
Call 801-899-6064Contact Our OfficeRogers & Russell, PLLC | Pleasant Grove, Utah | 801-899-6064
General information only; not legal or tax advice. No attorney-client relationship is created by contacting the firm. Tax Court appearances require admission to practice before that court or other applicable authorization; availability of representation is assessed individually. No outcome is guaranteed.